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A Tale of Two Continents Why the U.S. lags behind

A Tale of Two Continents Why the U.S. lags behind

by Erika Ginsberg-Klemmt

When you think of a household appliance, what do you picture? A toaster oven? Clothes dryer? Power tool? We tend to associate “household appliance” with a gadget that doesn’t generate electricity, but requires it. Cords, plugs and outlets are used with no fanfare as long as they serve loads on the electric grid. Which begs the question, why don’t we have appliances that generate electricity for the house, EV, batteries, and the grid?

Good question.

In 2023, Germany saw a quadrupling of legally interconnected Plug-In PV systems. This growth is underpinned by energy policies, electric codes, and safety standards that allow small solar generator systems to connect to the grid as simply as a household appliance. Such advancements have not only democratized solar energy, but have also catalyzed its adoption.

The rise of Plug-In Photovoltaic (PV) systems, or “Balcony Solar,” in Europe presents a compelling model that could revolutionize how North America embraces solar energy. Yet despite the undeniable success of Plug-In Solar in Europe, where regulatory frameworks have evolved to support this innovative deployment method, the U.S. has been slow to follow suit. The reasons are multifaceted, rooted in a complex web of regulatory hurdles, differing standards, and market dynamics that have made it challenging for Plug-In Solar to gain a foothold on American soil.

The United States still grapples with a patchwork of regulations and barriers that hinder the deployment of Distributed Energy Resources (DERs), varying not only from state to state, but from one municipality to another, creating an environment where the national adoption of Plug-In Solar is anything but straightforward. Some areas require no permits for small PV installations, while others have more stringent requirements. This lack of a comprehensive national law has left the U.S. trailing behind many advanced countries in plug-and-play solar adoption.

According to Joshua M. Pierce, Professor of Engineering at Western University, “Many advanced countries already allow plug-and-play solar, like the UK and most of continental Europe, yet US regulations have lagged behind. In some areas in the US, small PV installations require no permits, while in others, this is necessary. It depends on the utility and their rules, as there is no comprehensive national law.”1

The bureaucratic complexities extend further with 36,177 Authorities Having Jurisdiction (AHJs) and around ~3300 electric utilities in the U.S., often granting discretionary approval authority to unqualified personnel. This leads to hefty permitting fees and unnecessary project modifications, often based on arbitrary decisions. Such realities particularly exclude commercial and residential renters, as well as homeowners with smaller properties, from participating in the solar energy revolution.

In some jurisdictions, for instance, utilities demand extra liability insurance to protect the electric grid from potential damage by distributed solar generators, despite the technical inability of UL1741-compliant inverters to cause such damage. Additionally, the lengthy approval processes and individual “interconnect studies” required for small generators are not technically justifiable, especially for resources <15KW.

Progress amidst challenges: Recent developments

In recent years, the Department of Energy (DOE) has renewed its focus on the potential of Plug-In Solar. This shift in attention has led to efforts aimed at developing a new UL Standard specifically for Plug-In PV systems, marking a significant step forward. The DOE's recognition of the untapped potential for renewable generation, particularly for disadvantaged and underserved communities, is a promising development. These communities, often unable to benefit from traditional rooftop solar due to structural limitations or property ownership issues, stand to gain the most from the accessibility and affordability of Plug-In Solar solutions.

Pilot projects across various states have also begun to break new ground. In Texas and Colorado, for example, utilities have started to approve interconnection agreements for Plug-In Solar systems. These agreements are crucial as they set a precedent for other regions to follow, potentially easing the path for wider adoption. In California, a state known for its progressive energy policies, there has been mixed success; while some utilities have shown openness, others remain cautious, often citing concerns about compliance with the National Electric Code (NEC).

The path forward: Opportunities and obstacles

The potential of Plug-In Solar goes beyond just individual households. In disaster-prone regions or areas with unreliable grid access, the ability to quickly deploy portable, grid-tied solar solutions can be a game-changer. These systems offer not only a backup power source, but also a means to enhance community resilience and reduce dependency on centralized power grids.

As the U.S. continues to grapple with the challenges of Plug-In Solar adoption, there is growing recognition that the current regulatory framework may not be adequate to accommodate this new wave of solar technology. The ongoing work with Underwriters Laboratory (UL) to draft new standards, and the discussions surrounding the NEC, are vital steps in this direction. Yet, these efforts must overcome the inertia of existing systems and the reluctance of some stakeholders to embrace change.

One solution is to propose establishing legally permitted pilot sites across various U.S. regions. These sites would demonstrate how distributed, renewable electricity generation can work under real-world conditions, especially for marginalized groups. Mutual energy companies and forward-thinking conventional energy firms can play a crucial role here, leveraging their relationships with AHJs and utilities to establish favorable permitting procedures for such pilot projects.

The ultimate goal is to reach a state of “Nirvana,” where plug-in solar solutions like MEGA are seamlessly integrated into our energy systems without cumbersome and inconsistent approval processes. This entails influencing entities like the Department of Energy’s ASRAC Committee and the California Energy Commission to recognize grid-tied electricity generating household appliances (using flexible cords and code-compliant receptacles) as a legitimate category.

Where for art thou, U.S.?

“Balcony Solar” is overdue on this side of the pond. Homeowner or renter, everyone should have the opportunity to take control over how and when they use and store power, whether or not that power is coming off the grid. As AHJs begin to recognize the benign quality of plug-in solutions, individual adoption of renewable energy can thrive. Communities around the country will be better for it – and better able to weather whatever the weather throws at them.

The future of electricity generation should not be at the mercy of investor-owned utilities and their arbitrary and capricious rules which get rubber stamped by public service commissions nationwide. A comprehensive national law based on solid science that levels the playing field for all stakeholders is imperative. Such a law would eliminate the privileges and entitlements currently held by incumbent market players, leading to a more equitable and sustainable energy future. As we stand at the crossroads of energy innovation and regulatory reform, it's clear that the path to a greener future is paved with challenges. Yet, with the right mix of technological innovation, policy reform, and collaborative effort, the dream of a solar-powered North America is within reach.

Erika Ginsberg-Klemmt is VP Operations at Gismo Power, which specializes in the development of portable solar energy solutions for mobile, plug-in power.

Gismo Power  //gismopower.com

1 https://cybernews.com/tech/germany-balcony-solar-craze/

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